Transport Refrigeration Unit Regulation Updated Concept Webinar

March 19, 2020

Agenda

• Introduction & Background• Updated Concept • Draft Regulatory Language• Emission Inventory Updates• Health Analyses• Preliminary Cost Analysis • Next Steps

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New CARB Freight Actions (1st Board hearing dates shown)

Need for New TRU Regulation

• Despite progress made under existing TRU Regulation• Elevated health risk to nearby communities• SIP attainment (South Coast, San Joaquin Valley)• Increase in <25 hp units• Does not address refrigerant emissions

• In addition, need to transition to zero-emission to help meet multiple air quality, climate mitigation, and risk reduction goals

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Outreach Activities to Date

• 7 Public Workshops • 2 Workgroup Meetings • Mailed 40,000 postcards to facilities• Over 90 stakeholder calls and meetings

with TRU manufacturers, fleets, facilities, trade associations, and utilities

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Recap of Staff Concept from August/September 2019 Workshops

Public Comments Received

• No stranded assets • Diesel emission standards only• Infrastructure by 2024 is challenging• Implementation of zero-emission TRUs

should be sooner

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Updated Concept

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Summary of Updated Concept

Updated Concept: Applicable Facilities

• December 31, 2021:• Register with CARB

• December 31, 2022:• Submit SOTL compliance plan

• December 31, 2023:• Complete implementation of

SOTL compliance plan

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Updated Concept: Applicable Facilities

Facility Type DescriptionEstimated Statewide Population

Refrigerated Warehouses or Distribution Centers

Size ≥ 20,000 sq ft and has trailer TRU or TRU genset activity

2,175

Grocery StoresSize ≥ 15,000 sq ft and has trailer

TRU or TRU genset activity3,900

Intermodal Ports orRailyards

Ports or railyards with trailer TRU or TRU genset activity

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Total All Applicable Facilities 6,100

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Updated Concept: Truck TRUs

New• December 31, 2021:

• Lower global warming potential refrigerant

• December 31, 2023:• Full zero-emission

In-Use• December 31, 2023:

• Fleets phase in full zero-emission at 15% per year (over 7 years)11

Updated Concept: Trailer, Domestic Shipping Container TRUs, and TRU Gen Sets New

• December 31, 2021:• Lower global warming potential refrigerant (doesn‘t apply to TRU

Gen Sets)

• December 31, 2023:• Zero-emission operation when stationary >15 minutes at an

applicable facility • Electronic telematics system• NOx, PM, and CO emission standards

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Updated Concept: Trailer, Domestic Shipping Container TRUs, and TRU Gen Sets (Cont.)

In-Use• December 31, 2023:

• PM emission standard

• December 31, 2027:• Zero-emission operation when stationary >15 minutes at an

applicable facility • Electronic telematics system

• December 31, 2030:• NOx, PM, and CO emission standards

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Updated Concept: Railcar TRUs

New• December 31, 2023:

• NOx, PM, and CO emission standards

In-Use• December 31, 2023:

• PM emission standard

• December 31, 2030:• NOx, PM, and CO emission standards

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Updated Concept: Electric Utilities

• December 31, 2022:• Report to CARB on

number of Applicable Facilities requesting service, increased electricity demand, and schedule for completion

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Draft Regulatory Language

Draft Regulation Language

• Supersede existing TRU ATCM in 2021• Responsibilities for Applicable Facility Owners

and Operators, TRU Owners and Operators, TRU Manufacturers, Electric Utilities, Freight Contractors, Vehicle Owners, and Drivers

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Draft Regulation Language: Applicable Facility Owner Requirements• Report facility to CARB• Submit compliance plan • Complete compliance plan implementation• Report all TRUs to CARB or certify that non-

compliant TRUs are not allowed to operate onsite• Liable for SOTL violations within Applicable Facility

Geofence

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Draft Regulation Language:Applicable Facility Compliance Plan

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• Demonstrate how facility will ensure required TRUs use zero-emission operation when stationary >15 minutes• Daily average and maximum trailer TRU or TRU gen set

activity• Operational and Efficiency Strategies • Zero-Emission Fueling Infrastructure• Implementation schedule

Draft Regulation Language: Applicable Facility Compliance Extension

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• A compliance extension may be granted if certain circumstances prevent the installation of Zero-Emission Fueling Infrastructure • Delay in manufacture or shipment of infrastructure

equipment• Delay in obtaining construction permit(s)• Delay in installation of infrastructure• Delay in obtaining power from a utility• Delay in obtaining private financing

Draft Regulation Language: TRU Owner Requirements

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• Ensure TRU meets all regulatory requirements• Register TRU with CARB• Ensure TRU has valid CARB registration sticker• Liable for Trailer TRU and TRU Gen Set SOTL

violations

Draft Regulation Language: TRU Operator Requirements

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• Ensure TRU meets all regulatory requirements• Ensure TRU has valid CARB registration sticker• Liable for Trailer TRU and TRU Gen Set SOTL

violations

Draft Regulation Language: Freight Contractor Requirements

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• Ensure TRU meets all regulatory requirements• Verify TRU has a valid CARB compliance label (or) • Check TRU CARB identification number against

information contained within CARB’s website

Draft Regulation Language: Vehicle Owner and Driver Requirements

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• Ensure TRU meets all regulatory requirements• Verify TRU has a valid CARB compliance label (or) • Check TRU CARB identification number against information

contained within CARB’s website

• Liable for Trailer TRU and TRU Gen Set SOTL violations • Do not tamper with ETS• Allow CARB personnel to inspect TRU when requested• Provide information to CARB when requested

Emission Inventory Updates

Emission Inventory Updates

• TRU inventory documentation was released in October 2019 • https://ww3.arb.ca.gov/cc/cold-

storage/documents/hra_emissioninventory2019.pdf

• Subsequent updates include revisions to: • TRU populations • Number of TRUs currently using Alternative

Technology26

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TRU Statewide NOx Emissions

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TRU Statewide PM2.5 Emissions

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TRU Statewide GHG Emissions

Health Analyses

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Potential Cancer Risk and Risk Reduction at Cold Storage Warehouse

Notes:1. Residential Receptor. 30-year exposure duration. FAH: = 1 for ages less than 16.2. Represents the average risk from three meteorological data sets: Banning, Fresno, Watsonville.3. Results represent maximum values at the property boundary.

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Potential Cancer Risk and Risk Reduction at Grocery Store

Notes:1. Residential Receptor. 30-year exposure duration. FAH: = 1 for ages less than 16.2. Represents the average risk from three meteorological data sets: Banning, Fresno, Watsonville.3. Results represent maximum values at the property boundary.

Preliminary Cost Analysis

Supplemental Economic Document

• Upcoming Supplemental Cost Document for updated concept for the new TRU Regulation

• Intent is to provide stakeholders with staffs current cost related assumptions for facilities and equipment owners

• Feedback related to cost assumptions is welcome

Assumptions: Equipment

• Trailer and domestic shipping container TRUs will opt to comply with stationary operating time limit requirement by using electric plug-in technology

• Trailer and domestic shipping container TRUs with the ability to comply with the diesel TRU emission standard using a verified emission control strategy (VDECS) will do so until final compliance date

Assumptions: Infrastructure

• Applicable facilities and truck TRU home bases have same electricity cost currently, this will be updated in the future

• Assumption: infrastructure will be added at a 15% increment annually at home bases for truck TRUs

Assumptions: Infrastructure (con’t) • Current Cost per plug at applicable facility: $12,300

• Value for both dock door/ parking spot • Same # of parking lot plugs will be installed as

dock doors at refrigerated warehouse or distribution centers

• Based on the assumption that the facility would need no additional infrastructure (i.e. substation or transformer)

• No parking lot infrastructure at grocery and supercenters assumed

Cost Questions: TRU Owners/ Operators

• Are TRUs currently plugging in at ports? • Current operators of trailer TRUs that are less than

25 hp, which compliance path is more realistic: • Install a level 3 verified diesel emission control

strategy and wait until 2028/2031 to purchase a new unit

• Purchase a new compliant unit and avoid level 3 VDECS

Cost Questions: Facilities

• Consideration of cryogenic or fuel cell technology • TRUs idling?

• What percent of visits occur during: off-peak, peak and super-peak

• Ports: Current plug in system • Percent of the time facility is at full capacity infrastructure

operation • Cost Effectiveness/ Return on Investment Figures?

Next Steps

• Submit comments on draft regulatory language by March 27th

• https://www.arb.ca.gov/lispub/comm2/bcsubform.php?listname=truregulation-ws&comm_period=1

• Staff report available October 2020• 45-day formal comment period

• December 2020 board hearing

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Additional Information

• New TRU Regulation website: https://www.arb.ca.gov/newTRU

• Contacts:

Lea Yamashita, Lead StaffLea.Yamashita@arb.ca.gov(916) 323-0017

Cari Anderson, Chief, Freight Transport BranchCari.Anderson@arb.ca.gov(916) 324-0247

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